The FSA has made transitional arrangements for advertising in the transition from the previous CCA requirements. Old marketing material that complied with the 1989 CCA advertising regulations can remain in circulation for three months after the first day of mortgage regulation.
The confusion has arisen over a typographical error in transitional provision 6, referring to material that “satisfies the advertising requirements under CCA”. It should read “satisfied the advertising requirements under the CCA” so advertising promotions must have complied with the 1989 advertising regulations.
But Davies says intermediaries are unsure which regulations they should be complying with.
Given the confusion, the FSA now accepts TP6 to apply under either the 2004 or 1989 advertising regulations.